On March 01, 2019 a
Party Statement
was filed
involving a dispute between
Ramirez, Joe,
and
Apex Logistics, Llca California Limited Liability Company,
Class 8 Truck Repair, Llc A California Limited Liability Company,
Hartwick And Hand Llc A Nevada Limited Liability Company,
Hartwick & Hand, Inc A California Corporation,
Ramirez, Joe,
for Employment-Other-Complex
in the District Court of San Bernardino County.
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ORIGINAL
SOLOUKI SAVOY, LLP
Shoham J. Solouki, Esq. [SBN 278538] F- t L
.. .
Grant Joseph Savoy, Esq. [SBN 284077] SUPERIOR COURT oz: CALIFQ *
coumv 0:: 3AM BERNARDISSM
3 16 W. 2nd Street, Suite 1200 3A7» BERNARDINO msmm‘
Los Angeles, CA 90012
Telephone: (2 1 3) 8 14-4940 JUL 2 1:3
202!
I .
Attorneysfor Plaintgflana' the Proposed Class rv
cs. mmM/‘m
fifigflgafiwww .»
NA‘mAMEKEWJGEKTEP-UW
FAX \OOO\]O\
BY
10
11
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
FOR THE COUNTY OF SAN BENARDINO
14
15
16
JOE RAMIREZ, on behalf of himself and all Case: CIVDSI906586
17 other similarly situated non-exempt former
and current employees;
18 Assigned for A11 Purposes:
Hon. David Cohn
Plaintifi,
19
Dept. $26
vs.
20
CLASS ACTION
21 HARTWICK AND HAND LLC, a Nevada
Limited Liability Company; HARTWICK &
22 HAND, Inc., a California Corporation; DECLARATION OF BRYAN VALDEZ
APEX LOGISTICS, LLC, a California ON BEHALF OF CPT GROUP, INC. THE
23
Limited Liability Company; CLASS 8
SETTLEMENT ADMINISTRATOR
24
TRUCK REPAIR, LLC, a California
Limited Liability Company; and DOES l
25 through 10 inclusive
26 Defendants.
27
28
DECLARATION 0F BRYAN VALDEZ 0N BEHALF 0F CPI GROUP, INC. THE SETTLEMENT ADMINISTRATOR
DECLARATION OF BRYAN VALDEZ
I, Bryan Valdez, hereby declare:
1. I am employed as a Case Manager by CPT Group, Inc. (“CPT”), the Coult-appointed
Settlement Administrator for Ramirez V. Hartwick and Hand LLC, et al. I am authorized to make this
declaration on behalf of CPT. As the Case Manager for this settlement, I have personal knowledge ofthe
information provided herein, and if called as a witness, I could and would accurately testify thereto.
2. Settlement Administrator (“CPT”) has extensive expen'ence in providing court approved
KOOOVON
notice of class actions and administering various types 0f class action settlements. In the past 30-p1us
years, we have provided notification and/or settlement administration services in thousands of class
10 action cases.
11 3. CPT was selected by the parties and appointed by the Coun to provide notice of the
12 settlement and process exclusions in this action. In this capacity, CPT was responsible for: (1) preparing,
13 printing, and mailing simultaneously the Notice of Class Action Settlement in both English and Spanish
14 (hereinafier referred t0 as the “Notice Packet”); (2) receiving and reviewing any Opt—Outs; (3)
15 calculating payments under the settlement; (4) handing inquiries fiom Class Members concerning the
16 Notice Packet; (5) resolving any workweek disputes; (6) providing weekly status reports to Defendants’
17 counsel and Class Counsel regarding the mailings, Opt—Outs, and settlement payments; (7) distributing
18 settlement payments to Class members and payments to other parties under the tenns 0f this Joint
19 Stipulation; (8) providing due diligence declaration for submission to the Court, as needed; (9) printing
20 and providing Class Members and Plaintifiwith tax forms as required under the Joint Stipulation and
21 applicable law, and providing copies ofthe same to Defendants; (10) translating the Notice Packet to
22 Spanish; (1 1) sending, and/or responding to submissions of Opt-Outs, 0r contact information updates;
23 and (12) such other tasks as the Panies mutually agree or the Court orders the Settlement Administrator
24 to perform.
25 4. On April 16, 202 1 ,
CPT received the Notice prepared by the Panies and approved by the
26 CouIt.
27 5. On April 23, 202 1, the Defendant provided CPT with a mailing list (the “Class Data”)
28 which included an MS Excel spreadsheet 0f each Class Member’s: (1) name; (2) last known mailing
Page 2
DECLARATION 0F BRYAN VALDEZ 0N BEHALF 0F CPI GROUP, INC. THE SETrLEMENT ADMINISTRATOR
Document Filed Date
July 22, 2021
Case Filing Date
March 01, 2019
Category
Employment-Other-Complex
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ORIGINAL SOLOUKI SAVOY, LLP Shoham J. Solouki, Esq. [SBN 278538] F- t L .. . Grant Joseph Savoy, Esq. [SBN 284077] SUPERIOR COURT oz: CALIFQ * coumv 0:: 3AM BERNARDISSM 3 16 W. 2nd Street, Suite 1200 3A7» BERNARDINO msmm‘ Los Angeles, CA 90012 Telephone: (2 1 3) 8 14-4940 JUL 2 1:3 202! I . Attorneysfor Plaintgflana' the Proposed Class rv cs. mmM/‘m fifigflgafiwww .» NA‘mAMEKEWJGEKTEP-UW FAX \OOO\]O\ BY 10 11 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 FOR THE COUNTY OF SAN BENARDINO 14 15 16 JOE RAMIREZ, on behalf of himself and all Case: CIVDSI906586 17 other similarly situated non-exempt former and current employees; 18 Assigned for A11 Purposes: Hon. David Cohn Plaintifi, 19 Dept. $26 vs. 20 CLASS ACTION 21 HARTWICK AND HAND LLC, a Nevada Limited Liability Company; HARTWICK & 22 HAND, Inc., a California Corporation; DECLARATION OF BRYAN VALDEZ APEX LOGISTICS, LLC, a California ON BEHALF OF CPT GROUP, INC. THE 23 Limited Liability Company; CLASS 8 SETTLEMENT ADMINISTRATOR 24 TRUCK REPAIR, LLC, a California Limited Liability Company; and DOES l 25 through 10 inclusive 26 Defendants. 27 28 DECLARATION 0F BRYAN VALDEZ 0N BEHALF 0F CPI GROUP, INC. THE SETTLEMENT ADMINISTRATOR DECLARATION OF BRYAN VALDEZ I, Bryan Valdez, hereby declare: 1. I am employed as a Case Manager by CPT Group, Inc. (“CPT”), the Coult-appointed Settlement Administrator for Ramirez V. Hartwick and Hand LLC, et al. I am authorized to make this declaration on behalf of CPT. As the Case Manager for this settlement, I have personal knowledge ofthe information provided herein, and if called as a witness, I could and would accurately testify thereto. 2. Settlement Administrator (“CPT”) has extensive expen'ence in providing court approved KOOOVON notice of class actions and administering various types 0f class action settlements. In the past 30-p1us years, we have provided notification and/or settlement administration services in thousands of class 10 action cases. 11 3. CPT was selected by the parties and appointed by the Coun to provide notice of the 12 settlement and process exclusions in this action. In this capacity, CPT was responsible for: (1) preparing, 13 printing, and mailing simultaneously the Notice of Class Action Settlement in both English and Spanish 14 (hereinafier referred t0 as the “Notice Packet”); (2) receiving and reviewing any Opt—Outs; (3) 15 calculating payments under the settlement; (4) handing inquiries fiom Class Members concerning the 16 Notice Packet; (5) resolving any workweek disputes; (6) providing weekly status reports to Defendants’ 17 counsel and Class Counsel regarding the mailings, Opt—Outs, and settlement payments; (7) distributing 18 settlement payments to Class members and payments to other parties under the tenns 0f this Joint 19 Stipulation; (8) providing due diligence declaration for submission to the Court, as needed; (9) printing 20 and providing Class Members and Plaintifiwith tax forms as required under the Joint Stipulation and 21 applicable law, and providing copies ofthe same to Defendants; (10) translating the Notice Packet to 22 Spanish; (1 1) sending, and/or responding to submissions of Opt-Outs, 0r contact information updates; 23 and (12) such other tasks as the Panies mutually agree or the Court orders the Settlement Administrator 24 to perform. 25 4. On April 16, 202 1 , CPT received the Notice prepared by the Panies and approved by the 26 CouIt. 27 5. On April 23, 202 1, the Defendant provided CPT with a mailing list (the “Class Data”) 28 which included an MS Excel spreadsheet 0f each Class Member’s: (1) name; (2) last known mailing Page 2 DECLARATION 0F BRYAN VALDEZ 0N BEHALF 0F CPI GROUP, INC. THE SETrLEMENT ADMINISTRATOR